Charles
S French Charitable Trust

PRIVACY POLICY

WHO WE ARE AND WHAT WE DOThe Charles S French Charitable Trust (referred to as "the
Trust", "we", "us" or "our" in
this privacy policy) has a principal objective of providing grant
giving support to a wide range of charitable activities, primarily
within Essex and North East London, whilst maintaining and developing
the value of the Trust's investments and assets.

The Trust is a data controller and responsible for
your personal data.

Our data protection lead is Jamie Foster, one of
our trustees, who can be contacted at office@csfct.org.uk. If you
have any questions about this privacy policy, including any requests
to exercise your legal rights, please contact our data protection
lead.

We respect your privacy and is committed to protecting
your personal data and the personal data of anyone on whose behalf
you contact us. This privacy policy will inform you as to how we look
after personal data and sets out the basis on which any personal data
we collect from you, or that you provide to us, will be processed
by us.

Your visit to our website (which is referred to
as the "Site") and any communication with us is subject
to the terms set out in this privacy policy. Please read the following
carefully to understand our views and practices regarding personal
data and how we will treat it.
This policy is updated from time to time. The latest version updated
on 25 May 2018 is published on this page of the Site. All updated
versions of the policy will be published on the Site.

INFORMATION WE MAY COLLECT FROM YOUPersonal data, or personal information, means any information
about an individual from which that person can be identified. It does
not include data where the identity has been removed (anonymous data).
When you visit our Site or correspond with us in person or by letter,
phone, e-mail or otherwise you may give us information that would
be classed as personal data about you and others you are acting on
behalf of.
We may collect, use, store and transfer different kinds of personal
data which we have grouped together follows:

a.

Identity
Data which includes the first
name, last name, username or similar identifier, marital status,
title, date of birth and/or gender of you and others you are acting
on behalf of.

b.

Contact Data
which includes your email address and telephone numbers

c.

Health Data
which includes any information about a person's health on whose
behalf you contact us including medical history and/or current
health status.

d.

Technical Data which includes internet protocol (IP)
address, your login data, browser type and version, time zone
setting and location, browser plug-in types and versions, operating
system and platform and other technology on the devices you
use to access our Site.

e.

Marketing and Communications
Data which includes your preferences in receiving marketing
from us and third parties and your communication preferences.

We may collect Special Categories of Personal Data (as defined in
GDPR). This includes details about individuals' health, race or ethnicity,
religious or philosophical beliefs, sex life or sexual orientation.
We do not collect any information about criminal convictions and offences.

It is important that the personal data we hold about you and individuals
on whose behalf you contact us is accurate and current. Please keep
us informed if any personal data changes during your relationship
with us.

KEEPING PERSONAL DATA SECUREWe know that data security is important to you and it is therefore
important to us. We have put in place appropriate security measures
to prevent personal data from being accidentally lost, used or accessed
in an unauthorised way, altered or disclosed. In addition, we limit
access to personal data to those trustees, employees, agents, contractors
and other third parties who have a business need to know. They will
only process personal data on our instructions in accordance with
this policy and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal
data breach and will notify you and any applicable regulator of a
breach where we are legally required to do so.

HOW WE WILL COLLECT PERSONAL DATA
You may give us any of the categories of data identified above by
filling in forms on our Site or by corresponding with us by letter,
phone, e-mail or otherwise. This includes personal data you provide
when you:

-

visit our
Site;

-

make a request for a grant from
us;

-

give us information to enable monitoring
of grants provided;

-

give us information as a supplier or tenant of the Trust;

-

request marketing communications
to be sent to you;

-

give us some feedback.

WHY WE WILL USE PERSONAL DATAThe lawful bases for processing personal data are set out in Article
6 of the General Data Protection Regulation (GDPR). We may process
personal data on more than one lawful ground depending on the specific
purpose for which we are using the data. Please contact us if you
need details about the specific legal ground we are relying on to
process any personal data where more than one ground has been set
out below. At least one of these must apply whenever we process personal
data:

a.

Consent: you have given
clear consent for us to process personal data for a specific purpose.

b.

Contract: the processing
is necessary for a contract we have with you or because you have
asked us to take specific steps before entering into a contract.

c.

Legal obligation: the processing
is necessary for us to comply with a legal or regulatory obligation
(not including contractual obligations).

d.

Vital interests: the processing
is necessary to protect someone's life.

e.

Legitimate interests: the processing is necessary for
our legitimate interests (for example to administer and maintain
our website) or the legitimate interests of a third party unless
there is a good reason to protect personal data which overrides
those legitimate interests. We make sure we consider and balance
any potential impact on you and anyone on whose behalf you are
acting (both positive and negative) and your and their rights
before we process personal data for our legitimate interests.
We do not use personal data for activities where our interests
are overridden by the impact on you or anyone on whose behalf
you are acting (unless we have relevant consent or are otherwise
required or permitted to by law).

We rely on the following legitimate interests when processing
personal data:

-

To make grants in accordance
with our charitable objects;

-

To manage the Trust and comply
with our obligations to our tenants and suppliers;

We also need to satisfy specific conditions for processing certain
Special Categories of Personal Data, in particular which we may receive
about individuals for whom grant funding is requested. We rely upon
the following grounds in this regard:

f

The data subject has given explicit
consent to the processing of their personal data.

g

Processing is necessary in the
course of our legitimate activities as a not for profit body in
accordance with article 9(2)(d) of GDPR.

Click here
to find out more on the Information Commissioner's Office website
about the types of lawful basis that we will rely on to process your
personal data.
Generally we do not rely on consent as a legal basis for processing
personal data. However, where we do ask for consent we will do so
in order to comply with the principle that any processing must be
lawful, fair and transparent.

DISCLOSING PERSONAL DATA
We may have to share personal data with the parties below in order
to provide our services to you. We require all third parties to respect
the security of personal data and to treat it in accordance with the
law, and when they are processing personal data on our behalf we do
not allow our third-party service providers to use personal data for
their own purposes and only permit them to process your personal data
for specified purposes and in accordance with our instructions. Examples
of our third parties include:

a.

Sub-contractors for the performance
of any contract we enter into with them or you;

b.

Service providers acting as processors
who provide IT and system administration services,

c.

Professional advisers including
lawyers, bankers, auditors and insurers based who provide consultancy,
banking, legal, insurance and accounting services.

We do not transfer your personal data outside the European Economic
Area (EEA).

COOKIES
Consider whether you want a digital log of your visit to our Site
to be recorded in your browser. If you don't want a record to be kept,
you can choose to delete your browser history afterwards or view our
pages in incognito mode / private browsing, which won't store your
browser history, cookies, or search history after you've closed your
browsers. However, you are not invisible. Using incognito mode / private
browsing does not hide your browser history from your internet service
provider, us or your employer (if you are using a company device).

You can set your browser to refuse all or some browser cookies, or
to alert you when websites set or access cookies. If you disable or
refuse cookies, please note that some parts of this Site may become
inaccessible or not function properly.

CHANGE OF PURPOSE
We will only use personal data you provide us with for the purposes
for which we collected it, unless we reasonably consider that we need
to use it for another reason and that reason is compatible with the
original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose,
please contact us.

If we need to use your personal data for an unrelated purpose, we
will notify you and we will explain the legal basis which allows us
to do so.

Please note that we may process your personal data without your knowledge
or consent, in compliance with the above rules, where this is required
or permitted by law.

MARKETING
We strive to provide you with choices regarding certain personal data
uses, particularly around marketing for the purpose of contacting
you about the Trust's activities.

We may use your Identity, Contact and Technical Data to form a view
on what we think you may want or need, or what may be of interest
to you.

You will receive marketing communications from us if you have requested
information from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal
data with any other company for marketing purposes.

You can ask us or third parties to stop sending you marketing messages
at any time by logging into the Site and checking or unchecking relevant
boxes to adjust your marketing preferences or by following the opt-out
links on any marketing message sent to you or by contacting us at
any time.

HOW LONG WE WILL KEEP YOUR DATAWe will only retain personal data for as long as necessary to
fulfil the purposes we collected it for, including for the purposes
of satisfying any legal, accounting, or reporting requirements. We
retain personal data in accordance with our policy.

To determine the appropriate retention period for personal data,
we consider the amount, nature, and sensitivity of the personal data,
the potential risk of harm from unauthorised use or disclosure of
your personal data, the purposes for which we process your personal
data and whether we can achieve those purposes through other means,
and the applicable legal requirements.

In some circumstances we may anonymise personal data (so that it
can no longer be associated with you) for research or statistical
purposes in which case we may use this information indefinitely without
further notice to you.

YOUR LEGAL RIGHTSUnder certain circumstances, you have rights under data protection
laws in relation to your personal data. Please click on the links
below to access the Information Commissioner's Office website to find
out more about these rights:

If you wish to exercise any of the rights set out above, please Contact
us. If you are unhappy with how we are processing your personal data,
you have the right to complaint to the Information Commissioner Office.
The Information Commissioner can be contacted at:

NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a reasonable
fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these
circumstances.

WHAT WE MAY NEED FROM YOUWe may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal
data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person
who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our
response.

TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally
it may take us longer than a month if your request is particularly
complex or you have made a number of requests. In this case, we will
notify you and keep you updated.